Privacy Policy

1. Who controls your information

WealthDirector provides technology to financial advisors and institutions. How we handle your information depends on how you interact with us:

When you interact with us directly — for example, by browsing the Site, requesting an introduction, or corresponding with our team — WealthDirector is the controller of the information you provide, and this Privacy Policy governs that information.

When you access the platform through an advisor or institution — for example, as a client of a firm that licenses our platform under its own brand — that firm determines why and how your information is processed. In that relationship, the firm is the controller and WealthDirector acts as a processor that processes information on the firm's behalf and under its instructions. The firm's own privacy notice governs that information, and questions about it should be directed to the firm. We make information processed in this capacity available to the controlling firm and do not use it for our own independent purposes except as permitted by our agreement with the firm and applicable law.

2. Information we collect

Information you provide to us

When you request an introduction or otherwise contact us, we collect the information you choose to submit. Through our introduction form, this typically includes your name, firm or family name, role, email address, an optional phone number, and the contents of any message you send. If our relationship progresses, we may collect additional business and account information necessary to evaluate or establish access to the platform.

Information collected automatically

When you visit the Site, we and our service providers may automatically collect limited technical information, such as your IP address, device and browser type, operating system, referring pages, the pages you view, and the dates and times of your visits. We collect this information using cookies and similar technologies, as described below.

Information processed on behalf of a firm

Where we operate the platform for an advisor or institution, we process the information that firm and its authorized users place into the platform in order to deliver the Services to them. We process that information as a processor, as described in Section 1.

Information from other sources and inferences

We may receive information about you from other sources — for example, from an advisor or institution that refers you, from partners who help us arrange introductions, or from service providers that help us verify information or protect against fraud. We may also derive limited inferences from the information we hold, such as approximating your general location from your IP address.

Categories of personal information

We do not sell your personal information, and we do not share personal information for cross-context behavioral advertising.

3. How we use information

Where WealthDirector is the controller of your information, we use it to:

• respond to your inquiry, evaluate and arrange introductions, and communicate with you about access to the platform;
• operate, maintain, secure, and improve the Site and the Services;
• send administrative messages, such as confirmations, security notices, and changes to our terms or policies;
• understand how the Site is used so we can make it more useful;
• detect, investigate, and prevent fraud, abuse, and security incidents, and protect the rights, property, and safety of WealthDirector and others; and
• comply with our legal and regulatory obligations and enforce our agreements.

We may send you information about WealthDirector that we believe is relevant to your professional interest. You can opt out of these communications at any time using the unsubscribe link in the message or by contacting us.

4. Cookies and analytics

We use cookies and similar technologies to operate the Site, remember your preferences, keep the Site secure, and understand how visitors use it. We may use privacy-respecting analytics services to measure and improve Site performance. Most browsers let you remove or reject cookies through their settings; if you do, some parts of the Site may not function as intended. Where required by law, we present cookie choices through a consent tool on the Site, and we honor recognized opt-out preference signals (such as Global Privacy Control) where applicable.

Because there is no common industry standard for how to interpret "Do Not Track" (DNT) browser signals, the Site does not currently respond to them. We will update this section if a recognized standard is adopted.

5. How we share information

We share personal information only as described here:

• Service providers. With vendors who process information on our behalf — such as hosting, infrastructure, email delivery, and analytics — under contracts that require them to protect the information and use it only to provide services to us.
• With your advisor or institution. Where you reach us through, or request to be served by, a particular firm, we share relevant information with that firm to facilitate the relationship.
• Legal and safety. When we believe disclosure is required by law or legal process, or is necessary to protect the rights, property, or safety of WealthDirector, our users, or the public.
• Corporate transactions. In connection with a merger, financing, acquisition, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to the protections of this policy.
• With your direction or consent. When you ask us to share information, or otherwise consent to its sharing.
• Aggregated or de-identified information. We may share information that cannot reasonably be used to identify you.

Identity verification and financial-crime screening. In connection with the Services — including when you request an introduction through this Site and when the platform is used to onboard the clients of an advisor or institution — we and our service providers may verify identity and screen against sanctions, fraud, and anti-money-laundering (AML) watchlists, where required by law or by a firm's regulatory obligations.

The Site may link to third-party websites we do not operate or control. We are not responsible for their privacy practices, and their own policies govern any information you provide to them.

6. Your data and artificial intelligence

WealthDirector uses technology, including artificial intelligence, to provide and improve the Services. The following describe how we handle client information processed through the platform:

• We limit what automated processing can see. Our systems are designed so that automated and AI processing receives only the information needed to perform a specific task, and details that are not required for that task are masked or withheld.
• We do not retain processing data unnecessarily. Information used for a specific task is not kept beyond what is needed to complete it, unless retention is required to provide the Services or by applicable law.
• Identifiable information stays within the firm. Information that identifies a client and is processed for a firm remains within the platform's security controls and is not disclosed beyond that firm, except as the firm directs or applicable law requires. Results are returned to the client only through their advisor.
• We do not sell your information or use it for advertising. We do not sell personal information, and we do not use it to build profiles for cross-context behavioral advertising.

Within the platform, analysis and recommendations are surfaced to the advisor for review and approval; the advisor remains the source of advice that reaches the client.

7. Data retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy — for example, to respond to your inquiry, maintain our relationship, and meet our legal, regulatory, and compliance obligations — after which we delete or de-identify it. Where we process information on behalf of a firm, we retain and delete that information in accordance with our agreement with the firm and its instructions.

8. Security

We maintain administrative, technical, and organizational safeguards designed to protect personal information, including encryption of data in transit and at rest, role-based access controls, and separation of each firm's information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security; you are responsible for safeguarding any credentials associated with your access.

9. Where information is processed

WealthDirector is based in the United States, and we and our service providers process information in the United States and potentially other countries. If you access the Services from outside the United States, you understand that your information may be transferred to, stored in, and processed in jurisdictions whose data-protection laws may differ from those of your own. We take steps designed to ensure your information receives appropriate protection wherever it is processed.

10. Your rights and choices

Depending on where you live, you may have rights regarding your personal information, including the right to access, correct, delete, or receive a copy of it, and the right to opt out of certain processing. We do not sell personal information or use it for cross-context behavioral advertising. We will not discriminate against you for exercising your rights.

Residents of California (under the CCPA/CPRA), Texas (under the Texas Data Privacy and Security Act), and other states with applicable privacy laws may exercise these rights by contacting us using the details below. To protect your information, we may need to verify your identity before fulfilling a request, and an authorized agent acting on your behalf may be asked to demonstrate their authority. We will respond within the period required by applicable law (generally 45 days, which may be extended where the law permits and we notify you). Where we process information on behalf of a firm, please direct your request to that firm; we will assist the firm in responding as required.

Right to appeal. If we decline to act on your request, you may appeal our decision by contacting us at the email below within a reasonable time. We will respond to your appeal as required by applicable law. If your appeal is denied and you reside in a state that provides for it (including Texas), you may submit a complaint to your state attorney general.

If you are in the European Economic Area, the United Kingdom, or Switzerland, you may also have the right to object to or restrict certain processing and to lodge a complaint with your local data-protection authority.

11. Children's privacy

The Services are intended for financial professionals and adults, and are not directed to children under 18. We do not knowingly collect personal information directly from children under 18. If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to delete it.

12. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, where the changes are material, provide additional notice as required by law. Your continued use of the Services after an update takes effect indicates your acceptance of the revised policy, to the extent permitted by law.

13. How to contact us

If you have questions about this Privacy Policy or our information practices, contact us at:

WealthDirector Inc.
Email: legal@wealthdirector.ai